Page 2 of 2 FirstFirst 12
Results 41 to 62 of 62

Thread: Field Approvals - is there an appeals process?

  1. #41

    Join Date
    May 2017
    Posts
    1,449
    Post Thanks / Like

    Field Approvals - is there an appeals process?

    I always do a comparison of weight and speed of the aircraft they are already approved on and the subject aircraft I sighted weight and slower speed then certification by similarity is possible. Most wheels and brakes are TSO so they already have shown a minimum design standard. Sandy at Parker will often supply drawings that show maximum weight a given wheel is certified to, and provide the heat ability of the brake to convert velocity to heat. The other thing to look at is what the certification requirement for brakes are. Under aero bill 7a there is no requirement for brakes. Early versions of CAR 4 only required brakes with sufficient to hold the airplane still while doing your run up.


    Sent from my iPhone using Tapatalk

  2. #42

    Join Date
    Sep 2003
    Posts
    8,019
    Post Thanks / Like
    I could only find a requirement for brakes in CAR 4a under transport.

    I now have duplicate hard copy of almost everything imaginable - axial and radial loads, kinetic energy dissipation, torques, min/max assembly dimensions, part numbers, bleeding and conditioning, dimensions of Piper gear leg - and have requested a meeting.

    I might print up my excerpts from guidance documents (about triple what I posted above) and take them with me. But I always get lost in a big pile of paper.

  3. #43
    BC12D-4-85's Avatar
    Join Date
    Feb 2016
    Location
    Fairbanks, AK.
    Posts
    4,025
    Post Thanks / Like
    I'd make a brief one page executive summary of your substantiation. A simple list with numbered links to attached documents. Makes it easy going in for them and starts a dialog.

    Gary
    Likes phdigger123, marcusofcotton liked this post

  4. #44

    Join Date
    Sep 2003
    Posts
    8,019
    Post Thanks / Like
    So, an update. I met with three inspectors. I had data out the gazoo - installation drawings, torques, static and dynamic load data, kinetic energy dissipation, maintenance data, drawings with detailed dimensions, statements signed by the FAA proclaiming TSO on all parts, and more! Hard copy, in duplicate.

    I had submitted all of it electronically twice, to two different inspectors.

    They had my rejection letter ready, maintained they did not get my electronic submission, and refused to look at my hard copy. "We're done here!" was the exact phrase.

    I am going to re-submit, by physically handing the entire package in duplicate to the senior inspector, and addressing all points on the "declination" letter.

    But I need help with one item. They are saying (in writing) that I cannot have a field approval for Cleveland wheels and brakes because Robbie Grove holds an STC for his wheels and brakes on this aircraft. I know the FAA has a policy about not doing field approvals for already STCd installations, but do not believe it extends to different parts - I cannot find the FAA policy statement on the effect of STCs on field approvals.

    I do have all the 8300.16A Chg1 statements on use of STC data, but none of them address this exact issue. Help?
    Likes cubdrvr liked this post

  5. #45

    Join Date
    May 2017
    Posts
    1,449
    Post Thanks / Like
    Bob, you are making a different alteration. Grove uses his own brakes. You are using Cleveland brakes. That is sufficiently different from Robbieís STC. Suggest if that is the tact they want to take ask for a Field Approval to deviate from Robbieís STC by using Cleveland wheels and brakes and see what their reaction to that is. You are making an installation using different parts so you need approved data to deviate from the existing STC.

    Assuming they still stick to their guns, ask what office is the next higher in the chain (used to be region, but they did away with regions a while ago). I would also suggest a letter to your Congressman and both your Senators expressing how the FSDO is denying the use of your aircraft and denying a upgrade that will enhance safety for you and the general public. They hate dealing with Congressional inquiries.

    My offer is still open to give you a field approval on it. Once you have a Field Approval, there isnít much they can do as the paper goes direct to Oklahoma City and they will never see it.


    Sent from my iPad using Tapatalk
    Likes KevinJ, cubdrvr, wireweinie, Steve Pierce liked this post

  6. #46
    cubdrvr's Avatar
    Join Date
    Jan 2002
    Location
    YKN(mother city of the dakotas)
    Posts
    1,440
    Post Thanks / Like
    Bob...........I wanna be like you when I grow up !
    "Sometimes a Cigar is just a Cigar"
    Likes mixer, moneyburner liked this post

  7. #47

    Join Date
    Sep 2003
    Posts
    8,019
    Post Thanks / Like
    Thanks! And thanks for the offer! I was looking for the guidance that would discuss "what if" I was trying to put Cleveland wheels on the J3 (Cleveland does have that STC). I am sure they have to turn me down because of the previous STC. And I am just as sure there is no guidance that says if I want to put part Y on there and there is approval for part X, the X approval disallows a field approval for Y.

    I do want to see this through as a field approval. That is the correct way to do simple stuff like this, and it is encouraged specifically in AC 23-27.

    These guys have done a bunch of far more complicated approvals for me.

  8. #48

    Join Date
    Sep 2003
    Posts
    8,019
    Post Thanks / Like
    Cubdrvr - I get a lot of folks drifting through my hangar saying that! Trouble is, when you get to the point where you can do exactly what you want, whenever you want to, there is this big looming time limit.

    My plan is three Cub landings per day until I croak! I got the Stearman wing on the rotator, opened and closed nine hangars for display day, and did seven Cub landings. Too tired to go to the Sunday hangar party.
    Likes jrussl, mixer liked this post

  9. #49
    hotrod180's Avatar
    Join Date
    May 2008
    Location
    Port Townsend, WA
    Posts
    3,972
    Post Thanks / Like
    Quote Originally Posted by bob turner View Post
    .... They are saying (in writing) that I cannot have a field approval for Cleveland wheels and brakes because Robbie Grove holds an STC for his wheels and brakes on this aircraft.....
    Have you thought about taking the easy way out & just installing the STC'd Grove brakes?
    I dunno where the price point is but I've heard he makes good stuff.
    Cessna Skywagon-- accept no substitute!

  10. #50

    Join Date
    Sep 2003
    Posts
    8,019
    Post Thanks / Like
    Not my airplane, and doing this for free. Should have been trivial. Now it is a challenge.

    But yes - we have the Grove kit on a J3 (my partner wanted 26" tires for a rather scary backwoods attempt). We ran 26" for several hundred landings, then I found some 8:00s and mounted them. I run them at 32 psi on pavement,and consider the handling better than the originals, and way better than with the big Goodyears.
    Likes Farmboy liked this post

  11. #51
    mvivion's Avatar
    Join Date
    Jun 2003
    Location
    Bozeman,MT
    Posts
    12,352
    Post Thanks / Like
    I can’t even imagine dealing with this sort of nonsense. Life is too short, Bob, I’d take dga up on his offer, and move on.

    MTV
    Likes hotrod180, CubCruiser liked this post

  12. #52
    cubdrvr's Avatar
    Join Date
    Jan 2002
    Location
    YKN(mother city of the dakotas)
    Posts
    1,440
    Post Thanks / Like
    Mike.........I think Bob is beyond just getting the FA at this point. It's about accountability.
    "Sometimes a Cigar is just a Cigar"
    Likes Steve Pierce liked this post

  13. #53
    mvivion's Avatar
    Join Date
    Jun 2003
    Location
    Bozeman,MT
    Posts
    12,352
    Post Thanks / Like
    Quote Originally Posted by cubdrvr View Post
    Mike.........I think Bob is beyond just getting the FA at this point. It's about accountability.
    I hear that, and I’m pretty stubborn, but comes a time when I’d get it done, and let the local fed wonder…..I’m betting if Bob quit “annoying” them with logic, they might get suspicious, which is when the fickle finger would come in handy.

    MTV
    Likes Farmboy liked this post

  14. #54

    Join Date
    Sep 2003
    Posts
    8,019
    Post Thanks / Like
    Remember, this aircraft has been flying around with these wheels for a quarter century. It can probably just keep doing that. You should see how much other stuff I found. It makes no difference to my quality of life if this continues to be ignored.

    But I have done 17 complicated field approvals in the last decade and a half, with far less hassle. Same FSDO. I need to re-establish my credentials. This one should be trivial.

  15. #55
    skywagon8a's Avatar
    Join Date
    Mar 2008
    Location
    SE Mass
    Posts
    12,535
    Post Thanks / Like
    Just when you get a FSDO trained the personnel are changed, so you need to take the new group out behind the woodshed for a talking to. You need to work on the upper level management rather than the ones on the lower rung of the ladder. Good luck Bob.
    N1PA
    Likes Steve Pierce liked this post

  16. #56
    Steve Pierce's Avatar
    Join Date
    Mar 2002
    Location
    Graham, TX
    Posts
    22,230
    Post Thanks / Like
    I look at it as sport. Did you use AC 23-27
    Steve Pierce

    Everybody is ignorant, only on different subjects.
    Will Rogers
    Likes soyAnarchisto liked this post

  17. #57
    mvivion's Avatar
    Join Date
    Jun 2003
    Location
    Bozeman,MT
    Posts
    12,352
    Post Thanks / Like
    Best of luck, Bob……I hope you’re not inclined toward ulcers. That said, it is kinda fun to poke the pig every once in a while.

    MTV
    Likes skywagon8a liked this post

  18. #58

    Join Date
    Sep 2003
    Posts
    8,019
    Post Thanks / Like
    Thanks. 23-27 figures prominently in my pile of excerpts. I have so many excerpts printed up even I need a roadmap.

    They didn't give me the chance - the denial letter was printed before I got there. It oozes derision, and I found it insulting. Here is a fragment of an included sentence:

    "Because the data was not provided . . . it became very clear that getting adequate data from you describing this installation would be difficult, if even possible."

    Of course the meeting was to discuss my data, which I brought in printed form because they were complaining about the e-mail attachment format. I had almost 90 pages, in duplicate. They refused to even look. Can you believe 90 pages for a simple Cleveland wheel? It was as if they had never heard that these wheels actually work.

  19. #59
    RaisedByWolves's Avatar
    Join Date
    Feb 2005
    Posts
    4,858
    Post Thanks / Like
    Quote Originally Posted by bob turner View Post
    Thanks. 23-27 figures prominently in my pile of excerpts. I have so many excerpts printed up even I need a roadmap.

    They didn't give me the chance - the denial letter was printed before I got there. It oozes derision, and I found it insulting. Here is a fragment of an included sentence:

    "Because the data was not provided . . . it became very clear that getting adequate data from you describing this installation would be difficult, if even possible."

    Of course the meeting was to discuss my data, which I brought in printed form because they were complaining about the e-mail attachment format. I had almost 90 pages, in duplicate. They refused to even look. Can you believe 90 pages for a simple Cleveland wheel? It was as if they had never heard that these wheels actually work.

    Sounds like my field approval for previously approved fixed penetration wheel skis. He finally told me in the spring its spring time, what do you need skis for? He flat out refused to give a denial letter. I was already aggravated and didn't want to keep going. Funny I heard the same inspector took his posse of 3 to the seaplane fly in to ramp check people. I was talking to the owner of a beautiful turbine beaver and the same inspector has been harassing him about a canoe rack for the beaver, saying he can't use it even though it's on the type certificate.

    You'd think they would be here to help with aviation, maybe set up a table at the airport and helpfully go over paperwork, instead of handing out violations. Guess that is why they are everyone's favorite

  20. #60

    Join Date
    Jan 2016
    Posts
    101
    Post Thanks / Like
    Many of these new F-AYAY folks come from the military aviation side due to the 5-10 point hiring process advantage. Automatic top of the stack over a civilian person with better qualifications and knowledge. Unfortunately many donít have a clue nor desire to learn and help GA. Not bashing service people as I am one too. But thatís what most Gov jobs come down to, hiring points.

  21. #61
    txpacer's Avatar
    Join Date
    Jun 2011
    Location
    Iowa Park, TX
    Posts
    867
    Post Thanks / Like
    Quote Originally Posted by AKjurnees View Post
    Many of these new F-AYAY folks come from the military aviation side due to the 5-10 point hiring process advantage. Automatic top of the stack over a civilian person with better qualifications and knowledge. Unfortunately many donít have a clue nor desire to learn and help GA. Not bashing service people as I am one too. But thatís what most Gov jobs come down to, hiring points.
    No one can navigate the minutia of bureaucratic denial like a retired master sergeant

  22. #62
    wireweinie's Avatar
    Join Date
    Aug 2013
    Location
    Palmer, AK
    Posts
    4,781
    Post Thanks / Like
    Quote Originally Posted by txpacer View Post
    No one can navigate the minutia of bureaucratic denial like a retired master sergeant
    True. But what if he's on the other side of the fight?

    Web
    Life's tough . . . wear a cup.

Similar Threads

  1. T3 field approvals?
    By willhash in forum Modifications
    Replies: 101
    Last Post: 02-18-2021, 11:58 AM
  2. Field Approvals
    By bob turner in forum Modifications
    Replies: 3
    Last Post: 10-11-2004, 11:59 AM
  3. Field Approvals Again
    By StewartB in forum Modifications
    Replies: 12
    Last Post: 04-28-2003, 12:29 PM
  4. Field Approvals
    By cubdriver in forum Modifications
    Replies: 33
    Last Post: 10-23-2002, 02:45 PM

Bookmarks

Bookmarks

Posting Permissions

  • You may not post new threads
  • You may not post replies
  • You may not post attachments
  • You may not edit your posts
  •